SEC/CORPORATE - On November 1, the Division of Corporation Finance of the Securities and Exchange Commission (Division) published Staff Legal Bulletin No. 14I (SLB 14I), which provides new, issuer-friendly guidance on...more
The pay-to-play rules have expanded to FINRA capital acquisition brokers (“CABs”) and the investment advisers who use CABs to solicit governmental entities, which include public pension funds, for investment advisory...more
The SEC’s pay-to-play rule has given advisers reason to worry about potential foot faults since its adoption. As we have noted in prior posts, the rule is filled with landmines and is therefore difficult to navigate. As was...more
SEC/CORPORATE - SEC Approves NYSE Amendments Regarding Notice Related to Dividends and Stock Distributions - On August 14, the Securities and Exchange Commission approved a rule change which will now require New York...more
Editor's Note - DOJ Emphatically Ends Operation Chokepoint. After four years, the Department of Justice (DOJ) announced the formal end of its controversial Operation Chokepoint initiative. Launched in 2013, Operation...more
REGULATION - DOL Issues Additional Guidance on Fiduciary Rule - On January 13, 2017, the U.S. Department of Labor (“DOL”) issued a second set of guidance on its new fiduciary rules, which are scheduled to become...more